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32041500
TANNING OR DYEING EXTRACTS; TANNINS AND THEIR DERIVATIVES; DYES, PIGMENTS AND OTHER COLOURING MATTER; PAINTS AND VARNISHES; PUTTY AND OTHER MASTICS; INKSSynthetic organic colouring matter, whether or not chemically defined; preparations as specified in note 3 to this chapter based on synthetic organic colouring matter; synthetic organic products of a kind used as fluorescent brightening agents or as luminophores, whether or not chemically defined

Vat dyes (including those usable in that state as pigments) and preparations based thereon

Classification and applications of vat dyes

CN code 320415 covers vat dyes and preparations based thereon. Vat dyes are water-insoluble dyes that require chemical reduction (vatting) to a soluble form before application to fibres. Once applied to the fibre and oxidised, they return to their insoluble form, providing excellent wash and light fastness. Key vat dyes include synthetic indigo and anthraquinone derivatives. They are used mainly for dyeing cotton and cellulosic fibres, particularly in denim fabric production. Classification requires confirmation of the vat dyeing mechanism.

REACH and CLP chemical regulations

Vat dyes are subject to full REACH requirements. Substances must be registered with ECHA, and the importer must hold a current Safety Data Sheet. The vatting process using sodium dithionite (hydrosulphite) generates additional safety requirements related to the toxicity and flammability of the reducing agent. CLP labelling must account for both the dye and auxiliary agents in the case of preparations. Some anthraquinone-based vat dyes may be classified as harmful to the aquatic environment. Transport of vat dyes in powder form is subject to ADR regulations regarding combustible dusts.

Practical import and trade aspects

When importing vat dyes under CN code 320415, the chemical specification, Colour Index, CAS number, and commercial form should be presented. Synthetic indigo (Vat Blue 1) is one of the most important dyes in this group, used extensively in jeans production. Importers may benefit from EU tariff preferences. Quality control includes purity determination, heavy metal content, and moisture analysis. The vat dye market is dominated by producers from China and India, making origin and quality verification particularly important.

VOC standards and emission limits

When importing Vat dyes and preparations (CN 3204 15) into the EU, VOC content regulations under Directive 2004/42/EC must be considered. Decorative paints and automotive refinish products have established VOC limits. CLP classification requires appropriate GHS pictogram labelling on packaging. Pigments containing heavy metals (lead, cadmium, chromium VI) are subject to strict REACH restrictions (Annex XVII). Importers must have SDS sheets and ensure labelling complies with destination country regulations. Conformity testing may include spectrometric analysis for composition verification.

Frequently asked questions

Is synthetic indigo classified under CN code 320415?
Yes, synthetic indigo (Vat Blue 1, CI 73000) is classified under CN code 320415 as a vat dye. Natural indigo of vegetable origin is classified under code 320300 instead. The synthetic origin and vat dyeing mechanism of the substance are decisive.
What are the main hazards when working with vat dyes?
Main hazards include exposure to dye dusts (risk of respiratory irritation), contact with reducing agents (sodium dithionite is toxic and flammable), and potential aquatic toxicity of some anthraquinone dyes. Use of personal protective equipment in accordance with the SDS is required.
Is indigo import from China subject to special requirements?
Import of synthetic indigo from China is not subject to special restrictions beyond standard REACH, CLP, and customs documentation requirements. However, potential anti-dumping or countervailing duties should be considered and current trade defence measures should be verified in the TARIC database.
What VOC limits apply to paints and coatings CN 3204 15?
Paints and coatings under CN code 3204 15 are subject to VOC limits per Directive 2004/42/EC. Matt decorative paints: max 30 g/l, gloss decorative paints: max 100-150 g/l, industrial coatings: limits vary by application.